The Quality Policy Statement

Micro Precision LLC is committed to providing product that meets or exceeds customer requirements and expectations. Micro Precision LLC strives to enhance customer safisfaction through continious improvement of quality, delivery, price and the quality management system.

 

Guidelines for Contract Compliance and Awareness of Malpractice Prevention

1.0 SCOPE

1.1 The purpose of this specification is to clarify business ethics and standards of conduct. These guidelines apply to all aspects of work performed by direct Suppliers and their "sub-tier" Suppliers, including manufacturing,inspection, and services.

 

2.0 GENERAL

2.1 Suppliers (management and employees) are contractually obligated and expected to meet all purchase order requirements. Suppliers are required to inform sub-tier Supplier's hired by the Supplier that they are likewise contractually obligated and expected to meet all purchase order requirements.

2.2 Suppliers and sub-tier Suppliers shall be aware and vigilant for Malpractice and Fraud and Falsification (F&F), as it affects contract compliance. All parties associated with product and services destined for ultimate delivery to the Purchaser must be aware that Malpractice and F&F are grave and serious matters. The act of Malpractice or F&F has the potential for severe and costly damages.

2.3 It is the responsibility of all parties to avoid the slightest possibility or appearance of impropriety or malpractice and to report known or suspected occurrences to the proper authorities (See 2.6). All personnel working within the program must be aware of malpractice and fraud & falsification, pitfalls that could lead to malpractice and fraud & falsification, methods to eliminate potential situations, and Purchaser expectations of supplier's, their employees, and subcontractors.

2.4 Consequences of malpractice and fraud & falsification could involve functional failure of product in operation on land or at sea causing loss of equipment and life. Consequences also include severe dollar loss to the Purchaser, the Government, and the Supplier due to lengthy investigations, possible disqualification from future contracts, production shutdown, and loss of employment. Acts of malpractice or fraud & falsification will result in purc hase order contractual action and will also be subject o federal criminal prosecution for violations of law under Title 18 of the U.S. Code, Chapter 47, Section 1001.

2.5 Suppliers must ensure that employees and sub - tier suppliers are provided docum entation and information necessary to perform assigned and c ontracted work correctly. e m ployees and sub - tier suppliers must follow established work procedures and contract documents to perform best possible effort within the program. 7.4.2f2 Rev.1

2.6 Any party aware of, or having reason to suspect ,malpractice or fraud & falsification is obligated to report this violation anonymously or in person to: a.) Local Supervision or Management, b.) Purchaser Supervision or Management, c.) Purchaser Quality Represent ative, d.) Purchaser Buyer, or e.) Department of Defense Hotline * telephone (800) 424 - 9098 or * website http://www.dodig.osd.mil/hotline/hotline7.htm * email hotline@dodig.osd.mil or * mail to Department of Defense Hotline The Pentagon Washington, DC 20301 - 1900 Should such a notification be necessary, information including location, date(s), time, names of people involved, and violation suspected would be most helpful to promote an investigation.

2.7 False allegations of m alpractice and fraud & falsification are likewise serious matters and subject to federal investigation and prosecution. It is imperative that persons making allegations be knowledgeable and truthful with the facts and not be with vindictive or spitefu l intent.

 

3.0 CONTRACT COMPLIANCE

3.1 To demonstrate contract compliance with the specification, the Supplier is required to perform, and maintain records for, the following:

a.) Alert all employees to this (Contract Compliance and Awareness of M alpractice Prevention) Appendix during new hire indoctrination.

b.) Annually provide refresher training to this (Contract Compliance and Awareness of Malpractice Prevention) Appendix for all employees.

c.) Attachment 1 is provided as a visible re minder notice, and provides contact information should malpractice or fraud & falsification be observed or suspected. Suppliers are to post this reminder notice in conspicuous and prominent locations throughout the facility, especially work areas, at a minimum rate of one (1) copy for every fifty (50) employees.

d.) Include verification during internal quality audits that malpractice and F&F training is performed and reminder notices are posted.

e.) Include and awareness in audit requir ements that auditors be alert for malpractice and F&F during internal and external quality audits.

f.) Perform periodic and independent overchecks of final inspections and testing. 7.4.2f2 Rev.1

g.) Alert all sub - tier Supplier's of malpractice and F&F by passdow n of this specification in supplier purchase orders.

h.) While performing on - site quality audits at sub - tier Supplier's facilities, confirm and verify sub - tier awareness of malpractice prevention.

 

4.0 EXAMPLES OF MALPRACTICE AND FRAUD & FALSIFIC ATION (F&F)

* Issuing a procedure or instruction known to contain unauthorized deviation(s) to contractual requirements.

* Knowingly waiving or eliminating a contractual requirement without authority to do so.

* Deliberately accepting unsatisf actory work.

* Intentionally performing unacceptable work.

* Failing to report problems or unsatisfactory conditions in one's own workmanship.

* Verifying by signature that an action was taken, knowing in fact the action was not taken, or not perf orming the required checks or verification to assure the action was taken.

* Verifying performance of action based on hearsay, not personal observation.

* Tampering with calibrated instruments to avoid rejection of work.

* Falsifying dates on records to comply with frequency or deadline requirements.

* Falsifying data to cover - up a procedure or drawing deviation.

* Falsifying data to have work accepted, thereby avoiding further work or rework.

* Concealing or not reporting information on mal practice, fraud, or falsification know n to have been committed by others.